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Model Case Study: USDA Community Facilities Rural Health Clinic

Michal Mohelsky, J.D., Principal of MMCG InvestMichal Mohelsky, J.D., FMVA, Practicing Affiliate of the Appraisal InstitutePublished October 4, 2026

A 10,000 SF owned clinic for a rural nonprofit, financed with a $4,400,000 Community Facilities direct loan, $1,284,000 of local money and a $736,000 Community Facilities grant. The case shows how the grant is sized as the residual gap, how coverage is tested under the Community Facilities standard rather than a Business and Industry DSCR, and why the ramp years, not the stabilized year, decide the structure.

This is a model study. The subject, Cedar Fork Community Health Association, is a fictional nonprofit in a fictional town of 7,400 residents. No client data was used. Program rules, payment limits and benchmarks are cited to their sources; operating inputs are model assumptions and are labeled as such in the workbook, where every figure on this page traces to a cell.

At a glance

ItemAs proposedAs restructured
Subject10,000 SF rural health clinic, 8,800 SF clinic and 1,200 SF leased pharmacy suiteSame
BorrowerNonprofit operating a leased 4,500 SF clinic for more than five yearsSame
ProgramUSDA Community Facilities direct loan plus CF grantSame, with a 36-month principal deferral and a county assured-income pledge
Total project cost$6,420,000$6,420,000
CF direct loan$4,400,000 at 4.500 percent over 40 yearsSame
CF grant$736,000 (11.5 percent of cost)Same
Local contribution$1,284,000 (20.0 percent of cost)Same
Annual installment once amortizing$237,369$244,378
Coverage, Year 1negative (a shortfall of $420,006 after debt service and reserve)negative (a shortfall of $281,338 after debt service and reserve)
Coverage, Year 3 (first stabilized year)1.26x1.95x
Coverage, Year 4 (first amortizing year, restructured)1.54x1.90x (1.50x excluding the pledge)
Cumulative surplus (shortfall), Years 1 to 5($192,989)$433,229
Break-even visits, Year 418,910 with the pledge; 19,575 without
DeterminationNot supportable as proposed: the ramp years do not cover a level installmentSupportable with the deferral, the pledge and a liquidity condition

Determination

As proposed, the loan amortizes from the first year and the clinic ramps from 15,000 visits to 20,000. Coverage is negative (a shortfall of $420,006 after debt service and reserve) in Year 1 and 0.23x in Year 2, reaching 1.26x in the first stabilized year. The cumulative shortfall through Year 5 is ($192,989). Two years of debt service would have to come from the same reserves the applicant is contributing to the project, which is not a structure the 1942.17(h) revenue-sufficiency test accepts.

As restructured, three changes close the gap without changing the loan amount or the grant. First, the 36-month principal deferral available under 7 CFR 1942.17(f)(7)(i) reduces debt service to interest only, $198,000 a year, through the ramp, with amortization over the remaining 444 months at $244,378 a year from Year 4. Second, the county pledges $100,000 a year of operating support as assured income, which sits first in the nonprofit security order under 7 CFR 1942.17(g)(3)(iii)(A)(1). Third, the applicant retains working capital outside the project budget sufficient to carry the Year 1 shortfall. Coverage is negative (a shortfall of $281,338 after debt service and reserve) in Year 1, 0.73x in Year 2, 1.95x in Year 3 and 1.90x in the first amortizing year. Excluding the pledge, the first amortizing year covers 1.50x. The cumulative position through Year 5 is $433,229.

The volume cushion is thin either way. In Year 4 the restructured case breaks even at 18,910 visits with the pledge and 19,575 without it, against a base of 20,400. The independent feasibility study therefore has to document demand, and the conditions below are written around that.

The subject and the program

Cedar Fork Community Health Association has operated a 4,500 SF leased rural health clinic for more than five years, which satisfies the five-year operating test in the CF Direct Loan Guidance Book and allows real property and income to serve as security. It will build a 10,000 SF owned clinic with 8,800 SF of clinic space and a 1,200 SF retail pharmacy suite leased to a private operator. The clinic is an independent Rural Health Clinic paid at the national all-inclusive rate limit, which CMS set at $165.00 per visit for CY 2026 (MM14303, Transmittal R13505CP). It remains independent rather than seeking FQHC status, because FQHC economics (a CY 2026 PPS base of $207.72 and a 2024 medical cost per visit of $272.20 under HRSA UDS data) bring governance and sliding-fee obligations the board has not taken on.

Health care is an essential community facility under 7 CFR 5001.3 and an eligible CF project under 5001.103(a)(1). CF direct loans and grants are limited to rural areas and towns of up to 20,000 residents; Cedar Fork's 7,400 residents qualify. Three provisions shape the structure:

  • Coverage standard. 7 CFR 1942.17(h) requires revenues "sufficient to provide for facility operation and maintenance, a reasonable reserve, and debt payment." No minimum ratio is published. The 1.20x used to size the loan is a model convention, not a USDA rule, and the page says so wherever the ratio appears.
  • Poverty rate on income alone. 1942.17(f)(2) normally limits the poverty rate to projects meeting a health or sanitary standard, but that limit does not apply to facilities providing direct health care to the public. With a service-area median household income of $48,000 against a State nonmetro median of $64,000, the clinic is below the 80 percent threshold of $51,200 and takes the 4.500 percent poverty rate rather than the 4.750 percent market rate. That difference is worth $8,551 a year of debt service.
  • Leased space. The pharmacy suite is 12.0 percent of floor space. It clears the under-25 percent ceiling for loans and guarantees (7 CFR 5001.103(d); Guidance Book) and the tighter 15 percent "minor part" definition that governs grant funds (7 CFR 3570.53, 3570.63(a)(9)). Grant dollars are kept out of the suite, the lease goes to RD's Office of General Counsel for review, and the borrower may not lease any portion without RD's written consent (1942.17(n)(2)(xii)).

Rates are a live input. The most recently published CF direct rates, 4.500 percent poverty, 4.625 percent intermediate and 4.750 percent market, ran from April 1 to September 30, 2026. No rates for the period beginning October 1, 2026 had been posted at the date of record, so the first condition is a rate confirmation with the State Office and, if the rate has risen, a written request for the lower of the approval or closing rate under 1942.17(f)(1).

Project cost

UseAmountShare
Land$200,0003.1%
Site work$400,0006.2%
Building hard cost$4,000,00062.3%
Construction contingency$330,0005.1%
A/E, PAR, survey, environmental review$350,0005.5%
Legal, closing, appraisal, feasibility study$120,0001.9%
Medical equipment, furnishings, IT$800,00012.5%
Interim construction interest$220,0003.4%
Total project cost$6,420,000100.0%

Building hard cost is $400 per SF and is a model assumption to be replaced by the Preliminary Architectural Report estimate. Interim interest is a loan-eligible cost but is not grant-eligible (7 CFR 3570.63(a)(4)), and the pharmacy suite's share of hard cost is fenced from grant dollars, which together define the grant-eligible base below.

Capital stack and the grant gap

SourceAmountShare
CF direct loan$4,400,00068.5%
Applicant cash reserves$600,0009.3%
Community capital campaign$434,0006.8%
County capital contribution$250,0003.9%
CF grant (residual grant gap)$736,00011.5%
Total sources$6,420,000100.0%

The grant is sized last. The loan is sized first to the coverage convention, the local contribution is fixed at $1,284,000, and the grant is the residual: $6,420,000 less $4,400,000 less $1,284,000 equals $736,000. Under 7 CFR 3570.66(b) the grant is the lowest of three limits:

  1. The band percentage. The service-area median household income is below the 80 percent threshold ($51,200) but above the 70 percent threshold ($44,800), so the project qualifies for the 35 percent band and not the 55 percent band. The grant-eligible base is $5,720,000, which gives a band ceiling of $2,002,000. The $736,000 grant is 12.9 percent of the eligible base, well inside the ceiling.
  2. The minimum amount sufficient for feasibility (3570.61(d), 3570.66(b)(2)). This is the limit that binds, which is the outcome the regulation intends.
  3. The allocation test. The grant may not exceed the greater of 50 percent of the annual State CF grant allocation or $50,000 without an Administrator exception, so a $736,000 grant implies a State allocation of at least $1,472,000. The State Office must confirm. For scale, the Town of Paxton, Florida completed a rural health clinic with a $679,500 CF grant in May 2026.

Local money at 20.0 percent of cost earns joint-financing priority points under 1942.17(c)(2)(iii)(D)(3)(iii). Putting the grant on equipment keeps the 40-year loan secured by long-lived real estate, consistent with the useful-life limit in 1942.17(f)(7), and the Guidance Book makes RD grant funds the last money advanced. Emergency Rural Health Care grants were a one-time American Rescue Plan program and are not assumed. New Markets Tax Credits, made permanent at $5 billion a year with the CY 2026 round open, are not modeled at this project size because the leverage-loan structure would have to be fitted to RD's parity and security rules in 1942.17(g)(1).

Operating pro forma

Volume ramps from 15,000 visits in Year 1 to 20,000 in Year 3, then grows 2.0 percent a year. Stabilized capacity is 2.0 physician FTE at 3,800 visits, 4.0 NP/PA FTE at 2,800 and 1.0 behavioral health FTE at 1,200, which sits below the NARHC/Wipfli independent RHC productivity means and above the CMS productivity screens of 4,200 and 2,100. Net revenue per visit of $155.50 in Year 1 is the weighted result of the payer mix in the workbook (Medicare FFS 22 percent at $160, inside the $165 limit; Medicare Advantage 10 percent at $140; Medicaid 28 percent at $170; commercial 30 percent at $180; self-pay 10 percent at $47) and grows 2.5 percent a year from Year 2. Medicare Advantage, Medicaid and commercial rates are model inputs; the State RHC PPS rate must be obtained. Expenses inflate 2.5 percent a year from Year 2; support and administrative staffing is carried at 85.0 percent and 95.0 percent of the stabilized level in Years 1 and 2.

LineYear 1Year 2Year 3Year 4Year 5
Visits15,00018,00020,00020,40020,808
Net revenue per visit$155.50$159.39$163.37$167.46$171.64
Net patient revenue$2,332,500$2,868,975$3,267,444$3,416,112$3,571,546
Ancillary lab and imaging$90,000$110,700$126,075$131,811$137,809
Pharmacy lease$33,600$34,440$35,301$36,184$37,088
Total operating revenue$2,456,100$3,014,115$3,428,820$3,584,107$3,746,443
Provider compensation and benefits$1,235,000$1,414,500$1,449,862$1,486,109$1,523,262
Clinical support staff$357,000$408,975$441,262$452,294$463,601
Administration, front office, billing$408,000$467,400$504,300$516,908$529,830
Medical supplies and lab$165,000$202,950$231,138$241,654$252,650
Occupancy$90,000$92,250$94,556$96,920$99,343
IT and EHR$90,000$92,250$94,556$96,920$99,343
Malpractice$60,000$61,500$63,038$64,613$66,229
Other general and administrative$150,000$153,750$157,594$161,534$165,572
Total operation and maintenance$2,555,000$2,893,575$3,036,306$3,116,952$3,199,830
Net revenue before reserves and debt service($98,900)$120,540$392,514$467,155$546,613
Capital asset replacement reserve$60,000$61,500$63,038$64,613$66,229
Net revenue available for debt service($158,900)$59,040$329,476$402,542$480,384

Stabilized O&M of $151.82 per visit in Year 3 sits below the NARHC/Wipfli benchmark allowable cost per encounter of $155.18 to $169.36, which is consistent because the benchmark includes depreciation and facility cost that this model carries through debt service and reserves. The capital asset replacement reserve, required under 1942.17(i)(2), is 7.5 percent of equipment cost a year.

Coverage by year

Coverage is net revenue available for debt service divided by debt service plus the debt service reserve deposit, which 1942.17(i)(2) requires to build at no less than one tenth of an average installment a year until one installment is held.

StructureYear 1Year 2Year 3Year 4Year 5
As proposed: debt service$237,369$237,369$237,369$237,369$237,369
As proposed: reserve deposit$23,737$23,737$23,737$23,737$23,737
As proposed: coveragenegative0.23x1.26x1.54x1.84x
As proposed: cumulative surplus (shortfall)($420,006)($622,072)($553,702)($412,267)($192,989)
As restructured: county pledge$100,000$102,500$105,062$107,689$110,381
As restructured: debt service$198,000$198,000$198,000$244,378$244,378
As restructured: reserve deposit$24,438$24,438$24,438$24,438$24,438
As restructured: coveragenegative0.73x1.95x1.90x2.20x
As restructured: coverage excluding the pledgenegative0.27x1.48x1.50x1.79x
As restructured: cumulative surplus (shortfall)($281,338)($342,236)($130,135)$111,280$433,229

Break-even and sensitivities

Year 4 is the first amortizing year in the restructured case and the year a lender will test. Contribution per visit is net revenue per visit plus ancillary revenue less variable supplies, $162.07 in the base case.

CaseVisitsAvailable for debt serviceDebt service plus reserveCoverageBreak-even visits
Base20,400$510,231$268,8161.90x18,910
Market rate 4.750%20,400$510,231$278,0181.84x18,967
Visits -5%19,380$344,917$268,8161.28x18,910
Net revenue per visit -5%20,400$332,835$268,8161.24x19,983
O&M +5%20,400$354,383$268,8161.32x19,870
Without county pledge20,400$402,542$268,8161.50x19,575
Visits -5%, no pledge19,380$237,228$268,8160.88x19,575

A five percent volume miss alone leaves coverage at 1.28x; the same miss without the county pledge leaves 0.88x. The pledge, not the margin, is what carries a soft year. The market-rate case shows what an October 2026 rate increase would cost.

Conditions

  1. Rate confirmation. Obtain the CF direct rate letter for the period beginning October 1, 2026 before the Excel layer is locked. If the rate has risen, file the written request for the lower of the approval or closing rate under 1942.17(f)(1).
  2. Principal deferral and capitalized interest. The 36-month deferral under 1942.17(f)(7)(i) is a term of the loan, not a workout, and is requested at application.
  3. County assured-income pledge. A $100,000 annual operating commitment, documented and assigned, excluded from loan sizing and counted only in coverage.
  4. Applicant liquidity. The applicant retains unrestricted cash outside the project budget at least equal to the Year 1 shortfall shown in the restructured case, confirmed from audited statements at closing.
  5. Grant tests. State Office confirmation of the State CF grant allocation against the 3570.66(b)(3) test, and of the service-area and State nonmetro median household incomes from 5-year ACS data.
  6. Pharmacy lease. Market-rent support from a local broker opinion or the appraisal; the lease activity must be related to and enhance the facility's primary purpose (5001.103(d)); OGC review; RD written consent to lease.
  7. Feasibility report level. Prepared to examination-opinion content standards under the Guidance Book's Attachment E decision tree even if a compilation would be allowed, because the volume cushion is under two percent of base visits without the pledge.
  8. Demand documentation. Service-area physician supply from HRSA HPSA data against the 3,500 to 1 designation ratio in 42 CFR Part 5, Appendix A; age-specific visit rates applied to the ACS age profile, since the NAMCS rate of 320.7 office visits per 100 persons excludes community health center visits and is not age-adjusted; patient-origin data from the existing clinic's five years of audited statistics.

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Michal Mohelsky, J.D., Principal of MMCG Invest

Michal Mohelsky, J.D., FMVA

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